Foreign Passthru Payments for Dummies A Simplified Guide for 2017

FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... potentially foreign pass thru payments for calendar year. 2017. 2014. 2013. 2012. Page 15. PwC. (1) IGA: Intergovernmental Agreement. (2) ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... ... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ... ... foreign passthrough payments. Certain payees are exempt from FATCA ... 1, 2017, for offshore payments of U.S.-source income, 40 for ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed to work together, along with other partners, to develop a practical and ... ... foreign entities ("NFFEs"). To avoid ... 2017, the earliest. Additional regulations will be issued to provide guidance on passthru payments.